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U.S. CONSUMER PRODUCT SAFETY COMMISSION

LOG OF TELEPHONE CALL

SUBJECT: Firm’s request for an exception from the CPSIA section 101 lead content 

limit for children’s products of 100 ppm lead; CPSC staff posed general and specific 

questions; firm provided answers and explanations about the topics raised

DATE OF TELEPHONE CALL: 10/21/2011

LOG ENTRY SOURCE: Kristina Hatlelid

LOCATION: CPSC HQ, Bethesda, MD

CPSC PARTICIPANT(S): Kristina Hatlelid, Directorate for Health Sciences, and 

Thomas Caton, Directorate for Engineering Sciences

NON-CPSC PARTICIPANT(S): Jane Ertl and Bob Willits of Joseph L. Ertl, Inc., Scale

Models and Dyersville Die Cast

SUMMARY OF TELEPHONE CALL:

Discussion of aluminum alloys A380 and A413.1

• A380.1 is the most universally used aluminum alloy

• Most used alloy in Dyersville Die Cast is A413.1

• A413.1 is readily available

• A413.1 is more corrosion resistant than A380.1

• A413.1 costs about 6-10 cents per pound more than A380.1; this means an 

increased cost of several dollars for the end product

Lead in A380.1

• A380.1 lead content is about 600 ppm (National Association of Die Casting spec 

for A380.1 is 600 ppm lead); it is possible when working closely with a supplier, 

to obtain A380.1 with about 300 ppm lead with a small up-charge; concentration 

is right near 300 ppm lead

• Firm is comfortable with a 300 ppm lead limit for A380.1

Lead in A413.1

• A413.1 is guaranteed no more than 200 ppm; average about 125 ppm

• In addition, other customers require no more than 200 ppm lead for A413.1, and 

some customers test every shipment

• Firm is very comfortable with a 200 ppm lead limit for A413.1

Suppliers

• Firm works with three primary suppliers of aluminum, and contacted others

• Have not found a supply of casting alloy with less than 100 ppm lead
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• Suppliers indicate A413.1 may occasionally be found less than 100 ppm, but this 

is “accidental”

• A380.1 may be found less than 300 ppm; this is “accidental”, but by working 

closely with suppliers, the firm is able to purchase A380.1 with this lead level 

• Explained that there is difference between alloys that can be used for die casting, 

such as A380.1 and A413.1, and alloys that can be used with sand casting; 

alloys for sand casting cannot be used for die casting

Differences between A380.1 and A413.1

• Higher silicon in A413.1 tends to improve flowduring casting

• A413.1 is “stickier”

• Firm uses A413.1, lower in copper, which provides better corrosion resistance

compared to other alloys

Other 

• When firm changes from one alloy to another in production, a time-consuming 

clean out step is required before moving to next metal; if different alloys are not 

used, no clean out is needed

• Currently, toy production using A413.1

• Process for checking lead content during production: small disk is poured, 

cooled, and then analyzed for lead content with the in-house spectrometer (not 

an XRF; uses an electrode and light emission)

• Firm is 95% non-toy, but toy product line is very important to the company

Supplies

• 132,000 pounds is a “heat”; i.e., a single instance of alloy production

• Firm purchases 44,000 pounds (a truckload) at a time 

• Purchases 6-7 million pounds per year for all needs

Possible use of other materials

• Zinc

o The main issue with zinc is the weight; the final product would be very 

heavy and difficult for a child to use

o Also, existing tooling would become obsolete, would have to be changed; 

not clear that zinc die casting can be done with the large parts of the 

products

o Big cost difference on a product basis: the price for zinc alloy vs. 

aluminum alloy is not that different (about $1.20 per pound for aluminum; 

about $1.10 per pound for zinc), but because zinc is heavier, many more 

pounds of zinc are required per product

• Steel

o Use of steel would be stamping instead of die casting, resulting in a 

completely different product and using a completely different 

manufacturing process

• Magnesium
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o Magnesium can also be used in die casting, but it requires different 

equipment and a different process 

o It has hazards (fire), and also environmental impacts not seen with 

aluminum

o Unsure about lead content 

o Overall, this material is not a practical solution